UNITED BREWERIES LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 7, BANGALORE

In the result, the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

dividend income of Rs.8,57,655 and respectfully following the decision of the coordinate Bench of the Tribunal,(supra), we hold that the disallowance should be restricted to the amount of exempt income earned by the assessee. We direct accordingly.” 44.1 In view of the above order of the Tribunal, we direct the AO/TPO to restrict the disallowance

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

dividend income was received from one group company named M/s Mindtree Limited and the long term capital gain was also earned on sale of shares of M/s Mindtree limited. We notice that, as in the earlier year, the disallowance made by the assessee voluntarily is more than the amount of exempted income. Hence, we are of the view that

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BANGALORE vs. COFFEE DAY ENTERPRISES, BENGALURU

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

dividend income was received from one group company named M/s Mindtree Limited and the long term capital gain was also earned on sale of shares of M/s Mindtree limited. We notice that, as in the earlier year, the disallowance made by the assessee voluntarily is more than the amount of exempted income. Hence, we are of the view that

DEPUTY COMMISSIONER OF INCOME-TAX, , BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

dividend income was received from one group company named M/s Mindtree Limited and the long term capital gain was also earned on sale of shares of M/s Mindtree limited. We notice that, as in the earlier year, the disallowance made by the assessee voluntarily is more than the amount of exempted income. Hence, we are of the view that

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BANGALORE

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

dividend income was received from one group company named M/s Mindtree Limited and the long term capital gain was also earned on sale of shares of M/s Mindtree limited. We notice that, as in the earlier year, the disallowance made by the assessee voluntarily is more than the amount of exempted income. Hence, we are of the view that

M/S. PLAZA AGENCIES PVT LTD., ,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1) , BENGALURU

In the result, the appeal of the assessee is partly allowed

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year : 2018-19

deemed to have always applied in a case” which makes it clear that provisions of amended section 14A apply to case of assessment year 2018-19 under consideration in the present appeal also. 3) The Ld.CIT(A) also of the opinion that in view of the CBDT Circular 05/2014 dated 11.02.2014 which also brings out the legislative intent that section

M/S. CENTURY SILICON CITY,BANGALORE vs. DCIT, CIRCLE-1(2)(1, BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

deemed dividend under section 2(22)(e)). 3.4 The ld. CIT(A) observed that the distinction between legitimate tax planning and use of colourable devices has been summed up by Hon'ble Supreme Court, in the landmark judgement delivered by five-judge bench in case of Mc Dowell and Company Ltd Vs CTO (1985) (154 ITR 148) (SC), in following

M/S. CENTURY SILICON CITY,BANGALORE vs. DCIT, CIRCLE-1(2)(1, BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

deemed dividend under section 2(22)(e)). 3.4 The ld. CIT(A) observed that the distinction between legitimate tax planning and use of colourable devices has been summed up by Hon'ble Supreme Court, in the landmark judgement delivered by five-judge bench in case of Mc Dowell and Company Ltd Vs CTO (1985) (154 ITR 148) (SC), in following

CENTURY SHELTORS,BANGALORE vs. ACIT, CIRCLE-2(2), BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

deemed dividend under section 2(22)(e)). 3.4 The ld. CIT(A) observed that the distinction between legitimate tax planning and use of colourable devices has been summed up by Hon'ble Supreme Court, in the landmark judgement delivered by five-judge bench in case of Mc Dowell and Company Ltd Vs CTO (1985) (154 ITR 148) (SC), in following

CENTURY SHELTORS,BANGALORE vs. ACIT, CIRCLE-2(2), BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

deemed dividend under section 2(22)(e)). 3.4 The ld. CIT(A) observed that the distinction between legitimate tax planning and use of colourable devices has been summed up by Hon'ble Supreme Court, in the landmark judgement delivered by five-judge bench in case of Mc Dowell and Company Ltd Vs CTO (1985) (154 ITR 148) (SC), in following

M/S. CENTURY SILICON CITY,BANGALORE vs. DCIT, CIRCLE-1(2)(1, BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

deemed dividend under section 2(22)(e)). 3.4 The ld. CIT(A) observed that the distinction between legitimate tax planning and use of colourable devices has been summed up by Hon'ble Supreme Court, in the landmark judgement delivered by five-judge bench in case of Mc Dowell and Company Ltd Vs CTO (1985) (154 ITR 148) (SC), in following

CENTURY SHELTORS,BANGALORE vs. ACIT, CIRCLE-2(2), BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

deemed dividend under section 2(22)(e)). 3.4 The ld. CIT(A) observed that the distinction between legitimate tax planning and use of colourable devices has been summed up by Hon'ble Supreme Court, in the landmark judgement delivered by five-judge bench in case of Mc Dowell and Company Ltd Vs CTO (1985) (154 ITR 148) (SC), in following

CHINNASWAMY SUNDER RAJU,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(4), BENGALURU

In the result the appeal of the assessee is partly allowed

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyassessment Year : 2017-18

disallowed the Long Term capital Gain of Rs. 13,90,558/- and deemed dividend of Page 12 of 23 Rs. 2,41,72072/- and the assessment

REDDY HOUSING PRIVATE LIMITED ,BENGALURU vs. INCOME TAX OFFICER, WARD-5(1)(4), BENGALURU

In the result, appeal of the assessee is allowed for statistical purposes

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year : 2016-17 M/S. Reddy Housing Pvt. Ltd., Vs. Ito, #133/1 The Residency, 2Nd Floor Ward - 2, Residency Road, Hassan. H No.36B, Bommegowda Building, Paduvalu, Hippe Holenarasipur, Hassan– 573 211, Karnataka. Pan : Bsops 2078 N Appellant Respondent Assessee By : Smt. Narendra Sharma Adv Revenue By : Shri. Balusamy N, Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 12.11.2025 Date Of Pronouncement : 18.12.2025

disallowed under section 2(22)(e) of the Act as deemed dividend and added back into the income of the assessee

BOSCH GLOBAL SOFTWARE TECHNOLOGIES PRIVATE LIMITED ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

In the result, the appeal of the assessee is hereby partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2016-17

dividend income. On the contrary, the Ld D.R supported the order passed by Ld CIT(A). 9.2 We heard the parties on this issue and perused the record. We notice that opening balance of investments stood at Rs.25.59 crores in four schemes of mutual funds. During the year under consideration, the above investments have been realised. The assessee has made

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 2, LTU, BENGALURU vs. M/S. ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PRIVATE LIMITED, BANGALORE

In the result, the appeal of the Revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

dividend income. On the contrary, the Ld D.R supported the order passed by Ld CIT(A). 9.2 We heard the parties on this issue and perused the record. We notice that opening balance of investments stood at Rs.25.59 crores in four schemes of mutual funds. During the year under consideration, the above investments have been realised. The assessee has made

ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PRIVATE LIMITED,BENGALURU vs. THE JOINT COMMISSIONER OF INCOME TAX, LARGE TAX PAYERS UNIT, BANGALORE

In the result, the appeal of the Revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

dividend income. On the contrary, the Ld D.R supported the order passed by Ld CIT(A). 9.2 We heard the parties on this issue and perused the record. We notice that opening balance of investments stood at Rs.25.59 crores in four schemes of mutual funds. During the year under consideration, the above investments have been realised. The assessee has made

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

dividend income of Rs.8.47 crores and it has\nvoluntarily disallowed a sum of Rs.28.56 crores u/s 14A of the Act. We\nalso notice from the computation of income placed at page 65 of the\npaper book, the assessee has also earned Long term capital gain of\nRs.13 crores and claimed the same as exempt. Thus aggregate amount\nof exemption claimed

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BANGALORE vs. COFFEE DAY GLOBAL LIMITED, BANGALORE

In the result, all the COs by assessee in CO\nNos

dividend income of Rs.8.47 crores and it has\nvoluntarily disallowed a sum of Rs.28.56 crores u/s 14A of the Act. We\nalso notice from the computation of income placed at page 65 of the\npaper book, the assessee has also earned Long term capital gain of\nRs.13 crores and claimed the same as exempt. Thus aggregate amount\nof exemption claimed